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FinTech Risk Management Federal Reserve

Sheppard Mullin Richter & Hampton LLP

Fed Issues Cease and Desist Order for Crypto-Related Compliance and Risk Management Deficiencies

On September 4, the Federal Reserve Board (Fed) released enforcement actions against a Texas-based bank, addressing regulatory violations and compliance lapses. The Fed, joined by the Texas Department of Banking (TDB),...more

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Troutman Pepper on

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

McGlinchey Stafford

Deep Dive into Payments: Q&A on Bank Partnership Considerations

McGlinchey Stafford on

But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more

Morrison & Foerster LLP

Federal Reserve Issues Guidance on Novel Activities, Including Bank-Fintech Partnerships

On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

McGlinchey Stafford on

On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

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Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

Ballard Spahr LLP

Federal banking agencies issue final interagency guidance on risk management in third-party relationships

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The Federal Reserve, FDIC, and OCC have released final interagency guidance for their respective supervised banking organizations on managing risks associated with third-party relationships, including relationships with...more

Venable LLP

Banking Agency Guidance on Third Party Relationships

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Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more

Amundsen Davis LLC

Bad Relationships: New Regulatory Guidance for Banks on Managing Risks Associated with Third-Party Relationships

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On June 6, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly released final guidance on managing risks associated...more

Orrick, Herrington & Sutcliffe LLP

Agencies warn banks of crypto-asset liquidity risks

On February 23, the FDIC, Federal Reserve Board, and OCC released a joint statement addressing bank liquidity risks tied to crypto-assets. The agencies warned that using sources of funding from crypto-asset-related entities...more

Perkins Coie

Federal Reserve Issues Final Guidelines for Master Account Access

Perkins Coie on

The Board of Governors of the Federal Reserve System (the Board), on August 15, 2022, issued final guidelines for regional Federal Reserve Banks to use when considering applications for Federal Reserve “master...more

Sheppard Mullin Richter & Hampton LLP

OCC Highlights Focus on Crypto and Bank-FinTech Partnerships, Anticipates Stricter Scrutiny Going Forward

On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Eversheds Sutherland (US) LLP

Federal Banking Regulators Shine Light Again on Third-Party Risk Management

Federal banking regulators have again demonstrated their focus on bank oversight and management of risk from third party relationships through a series of guidance and proposed guidance published in the third quarter of 2021....more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

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In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

BCLP

Vetting FinTechs as Business Risk Partners: OCC Bulletin

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Innovation is a key to competitive advantage and keeping pace with consumer digital banking preferences. Increasingly, banks are engaging the services of fintech’s who can deliver certain information and services in a more...more

Morgan Lewis - All Things FinReg

Banking Agencies Release Proposed Guidance for Third-Party Relationships

Three federal banking agencies (the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency – collectively Agencies) issued proposed risk management guidance on July...more

Nelson Mullins Riley & Scarborough LLP

Continued Support for AI from the Financial Services Regulators

On March 29, 2021, the primary federal bank regulators (the Federal Reserve, CFPB, the FDIC, the NCUA, and the OCC) issued a request for information to gain input on the growing use of Artificial Intelligence (“AI”) by...more

Robins Kaplan LLP

Financial Daily Dose 10.8.2020 | Top Story: Feds fine Citi $400M over “Longstanding” Governance Failures

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Federal regulators—including the Federal Reserve and the OCC—have fined Citigroup $400 million over “longstanding” failures in the areas of risk management, data governance, and internal controls. In addition to the fine, the...more

Morrison & Foerster LLP

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

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